News and commentary about white-collar crime, enforcement, and compliance
Harry Cassin
Publisher and Editor
Andy Spalding
Senior Editor
Jessica Tillipman
Senior Editor
Bill Steinman
Senior Editor
Richard L. Cassin
Editor at Large
Elizabeth K. Spahn
Editor Emeritus
Cody Worthington
Contributing Editor
Julie DiMauro
Contributing Editor
Thomas Fox
Contributing Editor
Marc Alain Bohn
Contributing Editor
Bill Waite
Contributing Editor
Russell A. Stamets
Contributing Editor
Richard Bistrong
Contributing Editor
Eric Carlson
Contributing Editor
I wrote recently about the multiple meanings of “de-risking” and how compliance professionals need to know all those meanings. That post triggered a comment that took me by surprise. An old friend, whose job is to teach law school students about compliance, told me there’s a similar problem with another familiar compliance-related phrase.… Continue Reading
The Olympic figure skating scandal brought us back to basics. Do a risk assessment. Identify red flags. Conduct timely due diligence. Ensure adequate remediation.… Continue Reading
Compliance officers are experts at spotting red flags. They can discern potential FCPA violations from the other side of the world. But what about red flags closer to home — those that might impact a compliance professional’s career?… Continue Reading
Today’s hyper-transparent environment has given the public stunning opportunities to review internal communications from executives at leading companies and to pass real-time judgments on the strengths and vulnerabilities of their cultures.… Continue Reading
The European Investment Bank’s Inspectorate General Investigation Division started conducting Proactive Integrity Reviews (PIRs) in 2010, with the main objective to identify potential vulnerabilities and major fraud risks of EIB-funded operations and projects.… Continue Reading
As long as U.S. federal law enforcement priorities remain the same, licensed cannabis operators are unlikely to be prosecuted if they are completely compliant with state laws. However, if the DOJ or state regulators discover that a license was acquired through corrupt means, the license will not provide any protection.… Continue Reading
I see it time and time again — third parties that would otherwise pass muster under a client’s due diligence process create their own red flags.
They push back on a local registration requirement.… Continue Reading
Working with third parties continues to be the single biggest corruption risk for business. Almost one in two enforcement actions concluded since the OECD Anti-Bribery Convention came into force in 1999 was the result of bribery through sales agents, intermediaries, distributors or brokers.… Continue Reading
In the majority of bribery and corruption investigations — from relatively simple matters to complex cross-border affairs — the data necessary to detect and solve these cases was largely available within the organization under investigation and could have been used to prevent the red flag from erupting into a full-blown scandal.… Continue Reading
The SEC alleged Wednesday that two former anti-money laundering compliance officers for a New York broker dealer aided and abetted their firm’s AML violations.
One of the compliance officers settled the SEC charges.… Continue Reading
Recent enforcement actions suggest that regulators, both in the United States and the UK, are targeting compliance officers.
Some of these cases involve allegations that compliance officers took part in the misconduct, such as collusion between a compliance officer of a registered broker-dealer and his relatives to defraud investors and embezzle their money.… Continue Reading
ISO 37001– a new standard for anti-bribery management systems — slated to be published in late 2016, is expected to be more detailed and internationally recognized than similar guidance published to date.… Continue Reading